STIPULATION TO EXTEND TIME TO RETURN WAIVERS OF SERVICE OF SUMMONS AND RESPOND TO COMPLAINT FOR DEFENDANTS DEBRA GEE, JOHN GEE, THE GINSBURG TRUST, R. LANE JACOBSEN, J&P WALLACE FAMILY LIMITED PARTNERSHIP, LLP, ROBERT S. KLOSEK, CHRISTOPHER MARTIN, RICHARD S. RUBIN, MICHAEL SMITH, AND SANDRA S. SMITH

ROBERT C. JONES, Chief District Judge.

This Stipulation to Extend Time to Return Waivers of Service of Summons and to Respond to Complaint for Defendants Debra Gee, John Gee, The Ginsburg Trust, R. Lane Jacobsen, J&P Wallace Family Limited Partnership, LLP, Robert S. Klosek, Christopher Martin, Richard S. Rubin, Michael Smith and Sandra S. Smith ("Stipulation") is entered into by and among Robb Evans of Robb Evans & Associates LLC ("Plaintiff"), the Receiver over I Works, Inc. and over 60 other named Defendant Entities, as well as unnamed subsidiaries and affiliates thereof, and over the assets of Jeremy Johnson (collectively, the "Receivership Defendants"), and defendants Debra Gee, John Gee, The Ginsburg Trust, R. Lane Jacobsen, J&P Wallace Family Limited Partnership, LLP, Robert S. Klosek, Christopher Martin, Richard S. Rubin, Michael Smith and Sandra S. Smith (collectively "Defendants"), by and through their counsel with reference to the following facts:

RECITALS

A. The Plaintiff was appointed Temporary Receiver pursuant to a Temporary Restraining Order issued on January 13, 2011 in the civil enforcement action entitled Federal Trade Commission v. Jeremy Johnson, etc., et al., Case No. 2:10-cv-02203-MMD-GWF pending in the United States District Court for the District of Nevada ("FTC Action"). The Plaintiff became Permanent Receiver pursuant to a Preliminary Injunction Order issued on February 10, 2011. (The Court in the FTC Action is referred to as the "Receivership Court.")

B. On October 30, 2012, Plaintiff filed the Complaint in the above-captioned action.

C. On January 11, 2013, Plaintiff mailed Notices of Lawsuit and Requests for Waiver of Service of Summons to Defendants.

D. Pursuant to the Stipulation Regarding Arvin Lee Black, Jr. and Sole Group LLC Litigation and Order Thereon, approved by the Receivership Court on August 21, 2012, Defendants had until March 12, 2013 to return the Waivers of Service of Summons to Plaintiff.

E. Defendants have requested additional time to return the executed Waivers of Service of Summons to Plaintiff and to respond to the Complaint.

F. This Stipulation represents Defendants' first request for an extension of time to respond to the Complaint.

NOW, THEREFORE, in consideration of the foregoing, the parties hereto do stipulate and agree as follows:

1. The deadline for the Defendants, and each of them, to return executed Waivers of Summons of Service to Plaintiff shall be extended to and including March 19, 2013.

2. The deadline for the Defendants, and each of them, to respond to the Complaint shall be extended to and including March 19, 2013.

WHEREFORE, the parties pray this Honorable Court endorse this Stipulation as outlined herein and set forth below.

ORDER

IT IS SO ORDERED.